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Tax Strategy: Trump tax proposals and 2025 tax legislation

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2025 promises to be a very big year for tax legislation.

Having the White House, House and Senate all in control of the same party increases the likelihood that major tax legislation can be agreed upon. The Tax Cuts and Jobs Act was enacted in the first year of Donald Trump’s first term when Republicans also had control of the White House and Congress. Republicans are also likely to use budget reconciliation to enable the legislation to be enacted without any Democratic support by avoiding the filibuster rules of the Senate.

Republicans will still have to keep almost all their members on board given their narrow majorities in both the House and Senate. Budget reconciliation will also require Republicans to agree on a budget resolution that will specify the spending, taxes, and deficit to be allowed under the budget resolution, and then require the congressional committees to follow that resolution in crafting the legislation.

The two main focuses of the 2025 tax legislation are likely to be extension of and other tinkering with the provisions of the TCJA, many of which are currently set to expire after 2025, and enactment of the many tax-related proposals Trump has made on the campaign trail. The legislation will still be difficult to pull together, with many of the tax proposals coming at a high cost, and growing concern about increasing the size of the federal deficit.

Expiring TCJA provisions

President-elect Trump has proposed extending almost all the expiring provisions of the TCJA. These include:

  1. Maintaining the current tax rate brackets with a top rate of 37%;
  2. Maintaining the TCJA’s elevated standard deduction, which has resulted in around 80% of taxpayers claiming the standard deduction rather than itemizing;
  3. Continuing the elimination of the personal exemption;
  4. Continuing the elimination of miscellaneous itemized deductions in excess of the 2% floor, including unreimbursed employee business expenses, investment expenses, tax preparation fees, and safe deposit box rental expenses;
  5. Continuing the elimination of the Pease limit on overall itemized deductions;
  6. Continuing the 60% of adjusted gross income limit on charitable contribution deductions;
  7. Continuing the current $750,000 limit on the mortgage interest deduction;
  8. Continuing the current $2,000 Child Tax Credit with a $1,400 refundable amount;
  9. Continuing the current, more limited, individual alternative minimum tax; and,
  10. Continuing the current high level of the unified estate and gift tax exclusion amount, which is $13,990,000 for 2025.

The TCJA also included the $10,000 limit on the state and local tax deduction. Trump has mentioned perhaps letting that limit expire. Other proposals include at least doubling it for married filing jointly to $10,000 for each spouse or otherwise increasing the limit.

Several business provisions are also already phasing down. Republicans included retroactively extending these provisions in the Tax Relief for American Families and Workers bill in 2024. However, that bill failed to pass the Senate. These include:

  1. Restoration of 100% deduction for research and experimentation expenses;
  2. Restoration of 100% bonus depreciation, currently phasing down to 60% in 2024 and 40% in 2025; and,
  3. Restoration of the business interest deduction limitation to not include adjustments for depreciation, depletion and amortization.

A few business-related provisions of the TCJA are also scheduled to expire after 2025. These include:

  1. The 20% qualified business income deduction;
  2. The disallowance of the moving expense deduction, other than for members of the armed forces; and,
  3. Empowerment Zones and the New Markets Tax Credit, expiring at the end of 2025, and Opportunity Zones, expiring at the end of 2026.

Several of the international tax provisions of the TCJA are modified after 2025:

  1. BEAT increases to 12.5% from 10%;
  2. GILTI deduction drops from 50% to 37.5%;
  3. FDII drops from 37.5% to 21.875%; and,
  4. The look-through rule for controlled foreign corporations from other related CFCs expires.
trump-no-tax-on-tips-sign.jpg
Donald Trump during a campaign event in Las Vegas

Ian Maule/Getty Images

Trump’s campaign proposals

President-elect Trump made a number of tax proposals at campaign stops during the election campaign. Most of them lack detail as to how they would be implemented.

  • No taxation of tip income. This would be a new concept in the tax law. It would favor workers receiving tip income over other low-wage workers who do not receive tip income and might encourage employers to try to push more employees into tip income. It is not clear if it would include tips in kind or only cash tips. Taxation of tip income was already difficult to administer, and it is not clear if this would simplify administration or further complicate the issue. The proposal would be expensive.
  • No taxation of overtime. This would also be a new concept in the tax law. It also raises definitional questions of what constitutes overtime — e.g., does it include an employee who works more than 40 hours per week because the employee holds two jobs? It might encourage employees to try to maximize overtime pay versus regular pay. The proposal would also be expensive.
  • No taxation of Social Security benefits. This would be relatively easy to incorporate into the tax law since Social Security benefits are already not taxed to recipients under certain income levels. The proposal would be expensive and contribute to a more rapid depletion of the Social Security Trust Fund.
  • Deduction of car loan interest. This would be relatively easy to incorporate into the tax law since there is already a deduction for home mortgage interest. This proposal would also be expensive to adopt. It might help more taxpayers qualify for itemized deductions in excess of the standard deduction.
  • Elimination of double taxation of citizens living abroad. There are already several tax provisions designed to limit double taxation of citizens living abroad. These include tax treaties, the foreign tax credit, the foreign earned income exclusion, and the foreign housing deduction and exclusion. It is not clear if this proposal would try to modify these provisions or seek to revise the fundamental U.S. tax policy of taxing U.S. citizens on their worldwide income regardless of where they reside.
  • Elimination of clean energy credits. Trump has specifically proposed eliminating the clean energy credits with respect to electric vehicles. It is not clear how far this extends to other clean energy credits. Many Republican lawmakers have voiced support for some of the clean energy credits. This proposal would help to raise some revenue to offset the expense of some of the other proposals.
  • Corporate income tax. Although the corporate income tax rate established by the TCJA is permanent at 21% and not set to expire, Trump has proposed lowering it further to 18% or 20% and 15% for domestic manufacturers. This would also be an expensive provision that might be dropped due to deficit concerns.
  • Sovereign wealth fund. Trump has proposed establishing a sovereign wealth fund for investment activities by the government, similar to funds operated by several other countries. Trump has proposed funding it with tariffs and has predicted that it would be a revenue raiser for the country.
  • Tariffs. Trump has proposed a variety of tariffs as a favorite revenue raiser. These include a broadly applicable 10% or 20% tariff on imports, a 60% tariff of imports from China, and a 100% tariff on vehicles from Mexico. He has also recently proposed 25% tariffs on Canada and Mexico and an additional 10% tariff on China related to control of drugs coming into the U.S. Trump would have some freedom under current law to impose tariffs by executive action, although Congress could act to restrict that authority. Trump has suggested that tariffs could pay for many of his other tax proposals, although some commentators doubt that tariffs could raise that level of income. Trump has also suggested that tariffs could at some point replace the U.S. income tax, although again many commentators doubt that it could raise sufficient revenue. Tariffs would also tend to be much more regressive than the current income tax.

Summary

These are likely to be the discussion points around which 2025 tax legislation develops. As was done with the TCJA, there may be a tendency to try to get in as many tax breaks as possible, but to try to control the revenue cost by including phasedowns and phaseouts to stay within budget reconciliation requirements. The negotiations are likely to be difficult but also likely to end up with significant tax legislation enacted in 2025.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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